REPUBLIC OF THE PHILIPPINES

Metropolitan Trial Court

National Capital Judicial Region
Branch 132, Quezon City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

Criminal Case No. M-QZN-19-

13333-CR
- versus - For: VIOLATION OF BATAS
PAMBANSA BILANG 22

FILAMOR ISAGUIRRE y
PERALTA,
Respondents.
 x - - - - - - - - - - - - - - - - - - - - - - -x

MANIFESTATION AND MOTION TO SIGN AND

APPROVE THE AMENDED COMPLAINT

COMES NOW, private complainant INOCENTES REALTY & SALES

CORP. represented by EDITA U. CANARIA, through the undersigned
counsel, and unto this Honorable Court, most respectfully states, that:

1. On 31 March 2019, the complaint against herein respondent

Filamor P. Isaguirre was filed by herein complainant. A copy of the
Complaint-Affidavit is hereto attached and marked as “ANNEX A”;

2. On 02 May 2019, a Motion to Amend the Complaint-Affidavit

was filed to include MR. DANIEL BERNARDINO J. AURELIO as one of the
defendants because MR. AURELIO is an indispensable and necessary
party in the instant case being as a co-signatory/Chairman of NORTHEAST
DEVELOPMENT AND ACQUISITION CORPORATION;

The said Motion to Amend the Complaint Affidavit was received by

the Office of the City Prosecutor. A copy of the Motion to Amend the
Complain-Affidavit dated 02 May 2019 is hereto attached and marked as
“ANNEX B”;

3. However, the said Amended Complaint Affidavit was not signed

by the Assistant City Prosecutor in the signature part of the said Amended
Complaint Affidavit;

In view of the foregoing, it is most respectfully requested that the

Amended Complaint of the private complainant be signed and approved by
the Assigned Assistant City Prosecutor.

Accordingly, it is respectfully prayed that private complainant’s

Amended Complaint be corrected by affixing in the signature part the
signature and with approval of the Assigned Assistant Prosecutor of the
Office of the City Prosecutor.

Respectfully submitted.

_____ September 2022, Quezon City for Cainta, Rizal.

INOCENTES CANONIZADO
AND ASSOCIATES CO.
Counsel for Plaintiff
No. 19 Marunong St., Central District, Quezon City 1100
Tel No. 8-921-4775; Telefax No. 8-922-2804
Mobile No. 0906-584-3064
E-mail Address: icalaw@inocentes.com

By:

ATTY. VICENTE ROMULO B. PAGAOA

Roll No. 27524
IBP No. 174184/01-03-2022/Quezon City
PTR No. 2296446/01-03-2022/Quezon City
MCLE Compliance No. VI-000-8305/April 20, 2018
(Extended by virtue of B.M. No. 850)

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

MeTC 132
Quezon City

Greetings!

Please submit the foregoing MANIFESTATION AND MOTION TO SIGN

AND APPROVED THE AMENDED COMPLAINT for consideration and
approval of this Honorable Court immediately upon receipt hereof.

ATTY. VICENTE ROMULO B. PAGAOA

Copy furnished: By Personal Service/Registered Mail

VIMAR M. BARCELLANO
The City Prosecutor
Quezon City

CHARISMA REYDA Y. MANAUIS

Assistant City Prosecutor
Quezon City

ATTY. MARIANO C. MACANDOG

Counsel for the Accused
No. 16 Palad Compound, General Avenue,
Project 8, Quezon City

FILAMOR P. ISAGUIRRE
c/o NORTHEAST DEVELOPMENT AND
ACQUISITIONS CORPORATION
Darling Heights, Condominium,
Capitol Hills Drive, Old Balara,
Quezon City